Federal
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April 23, 2024
Int'l Pricing Pact Guidance Is Coming Soon, IRS Official Says
Updated Internal Revenue Service guidance that would help multinational corporations pursue advance pricing agreements will likely be released in a few months, an agency official said Tuesday.
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April 23, 2024
Migrant-Hiring Crimes And Tax Evasion Get Pair Prison, $1.8M Fine
A Florida federal judge has ordered two men to pay $1.8 million to the U.S. government and sentenced them to three years in prison after they confessed to recruiting migrants without employment authorization and failing to report workers' wages for tax purposes.
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April 23, 2024
Tomato Cos. Ask 9th Circ. To Allow Immediate Cost Deduction
Two companies that supply 40% of U.S. tomato paste and diced tomatoes asked the Ninth Circuit to allow deduction of their facilities' restoration costs during the tax year in which the tomatoes are processed, even though the companies don't pay the restoration costs until later.
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April 23, 2024
Atty Can Deduct $303K In Racing Ad Costs, 10th Circ. Told
A Colorado attorney asked the Tenth Circuit to reverse a U.S. Tax Court decision that prevented him from deducting $303,000 in advertising expenses tied to his automobile racing, saying the lower court incorrectly ruled that the costs were related to a hobby rather than his litigation practice.
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April 23, 2024
Feds Want About 3 Years In Prison For LA Bank Embezzler
The former chief financial officer at a community bank in Los Angeles should spend nearly three years in prison after admitting he embezzled more than $700,000 and used employee identities in a life insurance scheme, the government told a California federal court.
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April 23, 2024
Indicted 'Magician' Tax Preparer's Clients Under Scrutiny
Clients of a New York City-based tax preparer who earned the nickname "the magician," allegedly making $15 million while fraudulently depriving the IRS of $100 million, may also face charges, a prosecutor told the federal judge in charge of the case on Tuesday.
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April 23, 2024
IRS Opens Low Income Clinic Grant Period For 2025
The Internal Revenue Service has begun accepting applications from Low Income Taxpayer Clinics for matching funds in 2025, the agency announced Tuesday.
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April 23, 2024
DOL's Final Investment Advice Regs Expand ERISA's Reach
The U.S. Department of Labor issued final regulations Tuesday broadening who qualifies as a fiduciary under the Employee Retirement Income Security Act, backing off some changes included in a proposal the agency released in October.
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April 22, 2024
Hedge Funder's IRS Suit Over Leaked Tax Info Gets Trimmed
A Florida federal judge on Monday dismissed part of a hedge fund executive's case seeking to hold the Internal Revenue Service accountable for a leak of his private tax data to the media, saying he failed to show he suffered any damages.
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April 22, 2024
Congress Can Enact Corp. Transparency, Orgs Tell 11th Circ.
Congress is empowered to require American companies to report their beneficial owners to the federal government because there is ample evidence they've previously been used to fund hostile foreign actors, evade sanctions and traffic drugs, two think tanks told the Eleventh Circuit in an amici brief.
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April 22, 2024
Partnership Can't Claim $22.7M Loss, Tax Court Says
The U.S. Tax Court on Monday upheld the IRS' decision to deny a $22.7 million loss deduction claimed by a Connecticut partnership, finding that underlying transactions involving a bankrupt Brazilian company's debt obligations amounted to a disguised property sale.
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April 22, 2024
Fla. Man Fined After Failing To Report 11 Years Of Income
A Florida man is liable for penalties after failing to report approximately $7 million in income across 11 tax years, the U.S. Tax Court ruled Monday.
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April 22, 2024
Ga. Teacher Frivolously Disputed Deficiency, Tax Court Says
A Georgia man is required to pay a $15,000 penalty for maintaining a frivolous position in his challenge of an income tax deficiency, the U.S. Tax Court ruled Monday.
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April 22, 2024
IRS Failed To Act After Supervisor Groped Worker, Court Told
An IRS employee told an Iowa federal court Monday that her supervisor groped her and made a sexually degrading comment about her during a meeting but that the agency "has done nothing" to protect her, despite an investigation concluding the harassment had likely occurred.
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April 22, 2024
Va. Man Too Late, On Hook For $86K, Tax Court Rules
A Virginia man petitioned the U.S. Tax Court too late to contest his $86,000 liability, the court ruled Monday as it backed the Internal Revenue Service in the dispute.
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April 22, 2024
Conn. Couple Appealing $2.9M Tax Bill To 2nd Circ.
A Connecticut couple ordered to pay $2.9 million in back taxes, interest and penalties are asking the Second Circuit to reconsider the determination.
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April 22, 2024
Ex-US Atty's Stepson Says He Has None Of Docs Gov't Seeks
The stepson of a former Nevada U.S. attorney convicted of failing to pay taxes told a Nevada federal court that he doesn't have the financial documents the federal government has demanded in its $1.3 million tax suit against his stepfather.
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April 22, 2024
Chamberlain Hrdlicka Picks Firm Veteran As San Antonio Head
Chamberlain Hrdlicka White Williams & Aughtry announced Monday that it had tapped a shareholder with more than a decade at the tax-focused firm to helm its growing San Antonio location in the Lone Star State.
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April 22, 2024
Senate Bill Would Clarify IRS Process For Math Corrections
A bill introduced Monday in the U.S. Senate would clarify the process in which the Internal Revenue Service corrects math errors in tax returns.
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April 19, 2024
PE Exec Can Recoup $1M 'Varsity Blues' Forfeiture
A private equity executive whose conviction in the "Varsity Blues" college admissions case was almost entirely wiped out by the First Circuit is entitled to a refund of $1 million he paid to the scheme's ringleader, a federal judge ruled Friday.
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April 19, 2024
Utah Charity Leader Gets Year In Prison For $1.3M Tax Evasion
The former head of a Utah charity was sentenced to a year and a day in prison for evading taxes on $1.3 million he was paid as part of a covert arrangement with a purported donor, according to documents filed in a Utah federal court.
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April 19, 2024
IRS Previews New Digital Assets Reporting Form
The Internal Revenue Service released a draft of a form brokers will have to use for the first time to disclose their digital asset sales to the agency, including instructions for taxpayers whose transactions are subject to the reporting requirements.
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April 19, 2024
Atty Says False Testimony Justifies Chrisleys' Acquittal
Attorneys for Todd and Julie Chrisley of the reality television show "Chrisley Knows Best," who are in prison after being convicted on federal charges of bank fraud and tax evasion, urged the Eleventh Circuit to undo their convictions on Friday, arguing prosecutors knowingly presented false, prejudicial testimony at trial.
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April 19, 2024
Polsinelli Adds Shareholder To Tax Credit Practice In Dallas
An attorney who spent more than a decade developing a niche practice specializing in tax credit financing has moved her practice to Polsinelli PC's Dallas office after five years at Munsch Hardt Kopf & Harr PC.
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April 19, 2024
Atty In Tax Fraud Case Gets Supervised Release, $25K Fine
A former Houston lawyer whose conviction in connection with an $18 million tax scheme was overturned told a federal judge Friday that not testifying in his 2019 trial was "one of the worst mistakes" of his life as he was sentenced to a year of supervised release as part of a plea deal.
Expert Analysis
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Digital Taxation Is Necessary, But Tough To Manage
The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.
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5 Considerations When Seeking Federal EV Funding
A recent White House fact sheet shows how federal efforts to support the full scope of the electric vehicle industry have moved the needle, but some details about how to use those funds are still being ironed out, and there are a few issues to watch, say attorneys at Morgan Lewis.
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Unpacking The Inflation Reduction Act's Energy Tax Credits
Provisions in the recently enacted Inflation Reduction Act that affect how taxpayers can monetize clean energy tax credits will change how clean energy projects are financed, but taxpayers that may not be allowed multiple credits need to determine which type of credit will be the most advantageous, say attorneys at BakerHostetler.
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How COVID Has Changed Project Development And Finance
Two and a half years into the pandemic, some COVID-19-specific provisions are now common in the project development and finance markets, while others are still undergoing negotiation, say Nate Galer and Katy McNeil at Mayer Brown.
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Unpacking The Shift In DOJ Corporate Enforcement Policy
Attorneys at Paul Hastings provide takeaways for companies seeking to mitigate increased enforcement risks from the U.S. Department of Justice's recent corporate prosecution policy changes, including greater focus on individuals, requirements for cooperation credits, evaluations of prior misconduct, expectations for compliance programs and factors for determining whether to impose a monitor.
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What AML Bill Could Mean For Firms, Funds And FinCEN
If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.
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How Inflation Reduction Act Will Lift Offshore Wind Projects
The Inflation Reduction Act should promote the development of offshore wind energy in multiple ways — including by improving the planning and permitting process for transmission infrastructure, expanding potential lease areas and making beneficial changes to the tax credits available for renewable energy developers, say attorneys at Day Pitney.
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CORRECTED: New Tax Credits For Renewables Should Offer Investors Relief
The Inflation Reduction Act's changes to tax credits for renewable energy projects should finally liberate tax equity investors from the restraints of the complex and onerous federal anti-abuse regime, says Kay Hobart at Parker Poe. Correction: Because of an editing error, a previous version of this article incorrectly characterized tax enforcement regimes in North Carolina and other states. This error has been corrected.
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Inflation Reduction Act A Boon To Hydrogen, Carbon Capture
The Inflation Reduction Act's tax credits and direct payments, extension of existing renewable electricity subsidies, and other benefits will accelerate hydrogen and carbon capture projects across the U.S. — and will likely draw capital into the country that would otherwise have gone to projects elsewhere, say attorneys at Shearman.
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What The Inflation Reduction Act Has To Do With Crypto
The recently enacted Inflation Reduction Act’s $80 billion supplemental funding allotment for the IRS could have unexpectedly significant implications for the cryptocurrency market, which may find itself the target of ramped-up tax audits and enforcement, says cybersecurity consultant John Reed Stark.
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Unpacking The New Stock Buyback Tax And Its Exceptions
Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.
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Health Issues To Watch In Inflation Act, Other Policy Initiatives
The newly signed Inflation Reduction Act includes a number of significant drug pricing reforms, and the future holds a wider array of health issues that may be addressed in pending legislation when Congress returns in September, says Miranda Franco at Holland & Knight.
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How New Markets Tax Credit Can Help Pandemic Recovery
The New Markets Tax Credit program, designed to spur private investment in low-income, nonmetropolitan and distressed communities, is one potential remedy that can help alleviate the pandemic's negative impact on especially vulnerable areas, says Julia Fendler at Butler Snow.